Main issues of Decree 24/2012/ND-CP
The exclusive model of gold bar production, designating the SJC brand as "national standard gold", has seriously distorted the market. Domestic gold prices are often 12 - 20 million VND/tael higher than world prices, reflecting the distorted distribution and competition mechanisms. The State Bank, as both a management agency and a direct intervener by producing and importing SJC gold, fell into a state of "managing and participating in the market at the same time" - in conflict with market principles. This not only weakens confidence but also hinders private gold enterprises from participating in the equal market.
In addition, the system of licensing the trading of gold bars under strict conditions has created a "sub-license", suppressing the openness of the market. The lack of diversity in supply and rigid coordination mechanisms have caused investors and people to rush to store physical gold, instead of moving towards more effective and healthy investment channels.
The draft's content has not yet reached the level of innovation
The current draft has only adjusted techniques in some provisions such as expanding the target of gold bar production, regulating capital conditions, granting gold import limits... However, the core issue has not changed at a breakthrough level. Maintaining the charter capital requirement of VND 1,000 billion and the conditions for having a license to trade gold bars has limited opportunities for the majority of private enterprises - not in line with the spirit of private economic development in Resolution 68.
Meanwhile, the regulation that the State Bank continues to organize the production of gold bars shows the thinking of continuing to maintain monopoly in management. In particular, the Draft has not mentioned any content related to the development of the gold jewelry, processing and export market - while this is a potential field that can attract foreign currency, create jobs, increase domestic added value.
Requirements for innovation require controlled marketization and diversification of supply
In my opinion, in order to amend Decree 24, it is necessary to solve the following problems:
First, shift from monopoly to controlled competition. It is necessary to allow 5-7 enterprises with sufficient capacity and reputable brands to participate in the production of gold bars. The national gold standard set needs to be opened to many brands, instead of just SJC. This is an important measure to reduce price differences and healthy the market.
Second, clearly separate the roles of management and business. The State Bank needs to focus on the role of regulating, supervising, and issuing technical standards; not participating in production or administrative intervention in the supply chain. Organizing gold production requires businesses to take responsibility, following market principles and complying with post-inspections.
Third, remove institutional barriers and reduce sub-licenses. The buying and selling of gold bars should be considered a normal business activity, without a separate license, similar to many other high-value items. This will help smooth distribution and improve market efficiency.
Fourth, develop the jewelry and export gold market. Importing raw gold needs to be facilitated to be open and transparent. It is necessary to remove the regulation that businesses are only allowed to buy raw materials through commercial banks - which is not in accordance with the law and increases input costs.
Fifth, pilot the national gold exchange. It is time to seriously study the establishment of a centralized gold exchange or putting gold on commodity exchanges - according to the direction of the General Secretary. This is a necessary step to increase transparency, standardize prices and prevent speculation.
The amendment of Decree 24 needs to be seen as an institutional innovation, not just a technical adjustment. This must also be a test of the capacity to institutionalize those major policies into practice, creating a pioneering step in reforming the management of the financial - monetary market according to the principle of a socialist-oriented market economy.
